Karnataka Power Transmission Corporation Limited v. Rekha & Ors., 2026

The High Court's Single Judge and subsequently its Division Bench treated the writ petition as maintainable and held KPTC liable. Compensation of ₹25,52,500, with interest at 6% after three months from the judgment, was awarded using the multiplier method under the Motor Vehicles Act.

The connected matter concerned Muizz Ahmad Shariff, who jumped onto the roof of a neighbouring building to retrieve a cricket ball and came into contact with a 66 KV transmission line, suffering severe injuries. The High Court awarded ₹44,32,050, which was also upheld by the Division Bench. 

KPTC challenged the High Court decisions, particularly on the grounds that there were disputed questions of fact, that liability could not simply be imposed upon it, and that the writ remedy was inappropriate. 

The Court held that where disputed questions of fact arise in an electrocution compensation claim, a writ petition under Article 226 is generally not the appropriate remedy. Such disputes require proper fact-finding and can be pursued before the competent forum through an appropriate alternative remedy. 

The Court further clarified that the appropriate standard of liability for electricity transmission authorities is strict liability, rather than absolute liability. Electricity transmission is an inherently dangerous activity, and the entities undertaking it may be liable even without proof of negligence, subject to the recognised exceptions to strict liability. 

The Court also ruled that the Motor Vehicles Act multiplier method cannot be mechanically applied to electrocution cases. Since the Electricity Act, 2003 does not prescribe a specific compensation-calculation formula, compensation must be based on the overarching principle of just, fair and reasonable compensation, considering the victim's income and other relevant circumstances. 

The Court had earlier directed payment of ₹5 lakh as interim compensation. It clarified that this amount would not be recovered from the respondents and would not prejudice the amount of compensation that might ultimately be awarded by the appropriate forum. 

The Court relied on Radha Krishan Industries v. State of H.P., T.N. Cements Corporation Ltd. v. Unicon Engineers and, specifically for electrocution matters, Chairman, Grid Corporation of Orissa Ltd. v. Sukamani Das. 

In the present case, the Court identified several factual disputes, including whether the deceased's use of an aluminium ladder constituted negligence, whether the plantation owner was negligent, whether protective relays were functioning properly, and which entity was responsible for maintenance of the relevant electricity line.

This is one of the principal legal clarifications in the judgment.

The Court distinguished absolute liability, which does not permit the traditional exceptions, from strict liability, which operates subject to recognised exceptions.

The Court concluded that strict liability is the appropriate standard for electricity transmission authorities. Electricity is inherently dangerous, and those undertaking such an activity should bear the risks associated with it. However, liability is not automatically imposed in every conceivable circumstance because the recognised exceptions to strict liability remain relevant. 

The Court referred to the rule in Rylands v. Fletcher and earlier Supreme Court decisions including M.P. Electricity Board v. Shail Kumari and Union of India v. Prabhakaran Vijaya Kumar.

Volenti non fit injuria / consent; Common benefit; Act of a stranger; Statutory authority; Act of God / vis major; Default of the plaintiff; and Remoteness of consequences. 

This is significant because it demonstrates why the Court rejected treating electricity authorities as subject to absolute liability in every electrocution case.

The Court rejected the High Court's adoption of the Motor Vehicles Act multiplier formula.

The Court noted that Section 57 of the Electricity Act, 2003 addresses liability to pay compensation in specified circumstances but does not establish a detailed formula for calculating such compensation. Therefore, the compensation determination must be guided by the broader requirement of just, fair and reasonable compensation, having regard to income and other relevant claims. 

The judgment is important because it separates the existence of liability from the procedural route for establishing and quantifying that liability. Electricity authorities may face strict liability for electrocution, but where the circumstances of the accident, negligence, contributory negligence, maintenance responsibility or causation are disputed, those questions generally require adjudication before an appropriate forum rather than summary determination under Article 226.